Last week, the Clean Air Scientific Advisory Committee formally transmitted its recommendations to EPA Administrator Regan regarding the PM2.5 NAAQS. Consistent with trade press reporting over the past few months, the majority of CASAC members recommended that the PM2.5 NAAQS be set between 8-10 ug/m3. A minority recommended the range be set between 10-11 ug/m3. I’d be surprised if the revised NAAQS is set above 10 ug/3. 
For me,… More
On Monday, EPA promulgated amendments to its “Exceptional Events” Rule. The rule is important, particularly in the Western states, and most particularly in connection with EPA’s latest iteration of the ozone NAAQS. EPA’s most significant revision was to eliminate the requirement that state air agencies demonstrate that, “but for” the exceptional event, the state or relevant area would have complied with the applicable NAAQS. The change is important for two reasons. … More